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Ram Bahadur vs Bahadur Singh And Sri Ram And Ors. on 19 December, 1922

In the absence of a document embodying the terms of the security created by the deposit of title deeds, the lender could have proved the deposit by oral evidence and obtained the benefit of the security; but when the transaction was accompanied by an unregistered document their Lordships held that the creditor could not establish his security by oral evidence as to the deposit, even though the document was inadmissible by reason of non-registration (see also Ram Bahadur v. Dusuri Ram (1912) 17 C.L.J. 399). The same decision of the Judicial Committee answers the argument that though the contract between the lender and the borrower cannot be proved without the document, the fact of a loan could be proved. Under the daw, the mere deposit of title deeds (with intent to create a security) would suffice, but in the case referred to, their Lordships declined to allow even the fact of such deposit to be proved when the document turned out to be inadmissible. It is obvious that when the creditor is asking for permission to prove the fact of the loan, he is only seeking to invoke the theory of an implied promise to repay.
Allahabad High Court Cites 1 - Cited by 7 - Full Document

Maung Kyin vs Ma Shwe La on 26 July, 1917

28. The theory propounded by Ormond, J., in Maung Kyi v. Ma Ma Gale (1919) 54 I.C. 84 at 92 and 94 (F.B.) that in every case of a promissory note loan "there are two distinct promises made by the borrower (1) that be will pay the amount borrowed to the lender and (2) that he will pay the amount due on promissory note to the holder of the note " that each promise is a distinct cause of action and that Section 91 applies only to the 2nd promise, seems to me, with all respect, equally artificial, if the learned Judge meant to hold that even promise No. 1 was an express promise.
Bombay High Court Cites 9 - Cited by 56 - Full Document
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